Low tax effect makes Revenue appeal not maintainable under CBDT litigation limits, with merits left unexamined.

Revenue appeals below the CBDT-prescribed monetary limit are not maintainable, and the circular applies retrospectively to pending matters unless a recognised exception is shown. Here, the tax effect was below the appellate threshold, no exception to the circular was established, and the Tribunal dismissed the appeal without examining the merits of the underlying dispute. Liberty was reserved to seek recall if the matter later fell within an exception under the circular.

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Issues: Whether the Revenue appeal was liable to be dismissed as not maintainable because the tax effect was below the monetary limit prescribed in CBDT Circular No. 3/2018.

Analysis: The appeal was filed by the Revenue and the tax effect was undisputedly below Rs. 20 lakhs, the monetary limit prescribed for appeals before the Appellate Tribunal. The circular applied retrospectively to pending appeals, and no exception to the circular was shown to apply. The disposal was made without examining the merits of the underlying dispute, with liberty reserved to seek recall if the matter later fell within the circular's exceptions.

Conclusion: The Revenue appeal was not maintainable and was dismissed for low tax effect.

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